LTV Aerospace Corp. v. Renegotiation Board
United States Tax Court
Held: 1. Expenditures for research and development, which were made and properly capitalized in prior years and which were allocable to renegotiable business, were costs of renegotiable business in the year the project was abandoned and the expenditures were charged off against income. 2. Under the contractor's qualified profit-sharing plan, the contributions were to be computed and made on the basis of profits before reduction through renegotiation.
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Held: 1. Expenditures for research and development, which were made and properly capitalized in prior years and which were allocable to renegotiable business, were costs of renegotiable business in the year the project was abandoned and the expenditures were charged off against income. 2. Under the contractor's qualified profit-sharing plan, the contributions were to be computed and made on the basis of profits before reduction through renegotiation. Accordingly, such contributions were chargeable in full as costs of renegotiable business for years to which such contributions related. 3. It…
1Opinion of the Court
LTV Aerospace Corporation, Petitioner v. Renegotiation Board, Respondent
LTV Aerospace Corp. v. Renegotiation Board
Docket Nos. 929-R, 963-R
United States Tax Court
51 T.C. 369; 1968 U.S. Tax Ct. LEXIS 14;
December 16, 1968, Filed
Held: 1. Expenditures for research and development, which were made and properly capitalized in prior years and which were allocable to renegotiable business, were costs of renegotiable business in the year the project was abandoned and the expenditures were charged off against income.
2. Under the contractor's qualified profit-sharing plan, the contributions were to be…
2Cases cited17 opinions
- Cohen v. Secretary of WarUnited States Tax Court · 1946
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Ring Constr. Corp. v. Secretary of WarUnited States Tax Court · 1947
- Ring Const. Corporation v. Secretary of War of United StatesCourt of Appeals for the D.C. Circuit · 1949
- Wooster Rubber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
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